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Sector reference · housing providers

ESG reporting for housing providers: the sector standard, and the law around it

ESG reporting for housing providers runs on a voluntary sector standard, the Sustainability Reporting Standard for Social Housing, now in version 2.1.

It is not UK SRS, which is a different standard with a different owner and the same initials.

Whether any reporting is a legal duty depends on the provider’s legal form and size, and this page sorts the duties by both.

The sector standard

The Sustainability Reporting Standard for Social Housing, in its own terms

The Sustainability Reporting Standard for Social Housing is an ESG reporting standard created by and for the housing sector.

It was established in 2020, and Sustainability for Housing, which owns and maintains it, was set up in 2021.

The standard is open-source and free to report against, and only formal Adopters pay an annual contribution, according to SfH’s 2026 Annual Review.

Version 2.1 was released on 13 April 2026 and replaces version 2.0, which had been in use since 2023.

SfH has asked Adopters to report against v2.1 from the October 2026 reporting cycle.

Its guidance for v2.1 describes the approach as comply or explain: where a provider cannot yet report a criterion, it leaves the response blank and says in its public ESG report when it expects to.

That is the sector’s own use of the phrase, and it carries no legal consequence, unlike the FCA’s comply-or-explain rules for listed companies.

The 2026 Annual Review covers 104 Adopters managing over two million homes, from the 2024/25 dataset, which was reported against v2.0.

Sustainability for Housing guidance for v2.1 and Annual Review 2026.
PointPosition
OwnerSustainability for Housing, a company limited by guarantee run by a voluntary board
EstablishedStandard 2020; SfH 2021
StatusVoluntary, sector-led
Cost to useFree; formal Adopters make an annual contribution scaled by size
Versionv2.1, 13 April 2026, replacing v2.0 (in use since 2023)
Shape8 themes, an Adopter Profile, core and enhanced criteria
ApproachComply or explain, in SfH’s words

Same initials

The SRS and UK SRS are different standards

A search for “SRS” finds both.

They have no common owner, no common text and no legal link.

DBT, UK SRS S1 and S2; FCA PS26/19; Sustainability for Housing, v2.1 guidance.
UK SRS S1 and S2SRS for Social Housing
OwnerSecretary of State for Business and TradeSustainability for Housing
Built fromIFRS S1 and S2, the ISSB standardsCriteria developed with the sector, its lenders and investors
Who uses itAny UK entity; listed companies in five categories on comply or explain from 2027Housing providers that choose to adopt it
MaterialityFinancial: what could influence investors and lendersESG criteria set for the sector, including impacts on residents
Current versionPublished 25 February 2026v2.1, 13 April 2026
Legal forceNone of its own; comply or explain through the FCA’s listing rulesNone

Write the full name of each whenever both are in view: “UK SRS” for the national standards, and “the Sustainability Reporting Standard for Social Housing” for the sector one.

The national standards are read paragraph by paragraph on UK SRS S1 and UK SRS S2, which are built from the ISSB’s IFRS S1 and S2.

SfH says its standard keeps up to date with emerging frameworks such as UK SRS S1 and S2, and it responded to the government’s UK SRS consultation in September 2025.

The criteria

What the SRS asks a housing provider to report

The environmental criteria are the most numerical. These are a selection, by criterion number, from SfH’s v2.1 guidance.

Sustainability for Housing, Guidance for Version 2.1 (Spring 2026). Criteria outside the environmental block cover social and governance themes.
CriterionWhat is reportedEnhanced (optional)
C1Distribution of EPC ratings of existing homes, at the financial year-endAverage SAP rating; energy use intensity in kWh/m²/yr
C2Distribution of EPC ratings of new homes completed in the yearAverage SAP rating of new homes
C3Whether there is a net zero target and strategy, and the target dateWhether it is SBTi-aligned; whether there is a costed transition plan
C4Progress towards net zero, and retrofit activity in the last 12 monthsHomes retrofitted, as a number and a share of what remains
C5Scope 1, 2 and 3 emissions, and total emissions per homeWhether the provider qualifies for SECR; the SECR intensity ratio
C6–C8Whether flood, water-stress and overheating risks to homes have been mapped and assessed in the last two yearsOther physical risks; transition risks

The guidance asks for Scope 3 by the fifteen categories of the GHG Protocol, rather than as one total, so that confidence in each category can be stated.

It names purchased goods and services, capital goods, use of sold products and downstream leased assets as the categories likely to matter most for a housing provider, following the GHG Protocol.

It asks landlords to report regulated emissions from their homes, the fabric and heating they control, rather than residents’ plug-in use.

The climate-risk criteria ask about physical risks to the housing stock: flooding, water stress, overheating and, in the enhanced criteria, wildfire and storms.

Version 2.1 also aligned the damp and mould criteria with Awaab’s Law and added a tab mapping the STAIR and ARC reporting requirements to the standard.

Three governance criteria that rarely change, such as the code of governance followed, moved into a new Adopter Profile at the start of the report.

The law

Which reporting duties reach a housing provider, by legal form

No statute imposes an ESG reporting duty on housing providers as a class.

What reaches a provider is decided first by its legal form, then by its size, and then by what it has listed.

A registered society is a body corporate under section 3 of the Co-operative and Community Benefit Societies Act 2014, but it is not a company, so the Companies Act reporting duties do not reach it as such.

A provider that is a company is in SECR if it exceeds at least two of £36 million turnover, £18 million balance sheet and 250 employees, under Schedule 7 paragraph 20B.

ESOS reaches any undertaking that is large under Schedule 1 to the ESOS Regulations, and a registered society is an undertaking because it is a body corporate.

Public bodies are excluded from ESOS by regulation 16; whether a particular provider counts as one is a legal test, and worth checking rather than assuming in either direction.

The climate duty in section 414CA reaches only companies with more than 500 employees in its categories, and a company with listed bonds can be one, because a traded company is one with any transferable securities on a UK regulated market.

The FCA’s UK SRS rules do not reach bonds: debt and debt-like securities in UKLR 17 are excluded by PS26/19 ¶3.7.

How the FCA’s rules work for the companies they do reach is on the FCA and UK SRS.

Housing provider duty check

1 reporting duty reaches you on these answers.

  • SECRNot this routeSECR is written into the Companies Act directors’ report. A registered society is a body corporate but not a company, so Schedule 7 does not reach it as such; check the accounting requirements that bind you.SI 2008/410 Sch 7; CCBS Act 2014 s.3
  • ESOSIn scopeA large undertaking on these figures — a registered society is a body corporate, so it is an undertaking. Qualification is judged on 31 December 2026; notification by 5 December 2027. Whether a provider is a "public body" is a legal test worth checking, not assuming.SI 2014/1643 Sch 1 ¶¶1, 1A; regs 4, 15, 16
  • Climate-related financial disclosureNot this routeThe strategic report duty is a Companies Act duty and does not reach this legal form.CA 2006 s.414CA
  • FCA listing rulesExcludedDebt and debt-like securities are listed under UKLR 17, which the final rules exclude. A bond issuer is not required to report against UK SRS by them.FCA PS26/19 ¶3.7
  • Regulator of Social HousingStandards applyThe consumer standards apply to registered providers in England. They set outcomes on safety and quality, transparency, neighbourhood and tenancy; they are not a sustainability reporting standard.RSH Consumer standards Code of Practice, 1 April 2024
  • Sustainability Reporting Standard for Social HousingVoluntaryThe sector-led ESG standard, v2.1, used in the October 2026 reporting cycle. Free to use; formal Adopters make an annual contribution.Sustainability for Housing, SRS v2.1 guidance
  • UK SRS S1 and S2VoluntaryAvailable for voluntary use by any entity. No requirement or threshold for unlisted bodies has been proposed.DBT, UK SRS guidance, 25 February 2026

Indicative, not advice.

It reads one set of figures for one entity; group structures, public-body status and the two-year rules need the provisions themselves.

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Wording

The SECR test for a housing company, word for word

A landlord’s homes sit on its balance sheet, so the balance-sheet limb is the one to check first.

The test is written as an exemption: a company is exempt if it meets two or more of the “not more than” conditions.

So the figures are thresholds to be exceeded, and a provider with exactly £36 million of turnover is not over that limb.

Guidance written for the sector sometimes says “£36m or more”; where wording differs, the Schedule governs.

A change of side takes effect only once it has held for two consecutive years.

The SRS asks in its enhanced criterion C5E whether a provider qualifies for SECR, and for the SECR intensity ratio if it does, so the two sit side by side in a provider’s report.

The provision-level reading, including LLPs and groups, is on SECR thresholds.

SI 2008/410 Sch 7 ¶20B(2): exempt where two or more are met.
LimbStatutory wordingA provider exactly at the figure
TurnoverNot more than £36m (exempt side)Not over the limb
Balance sheet totalNot more than £18mNot over the limb
EmployeesNot more than 250Not over the limb

The regulator

The Regulator of Social Housing and the 2023 Act

The Social Housing (Regulation) Act 2023 reformed the consumer regulation of social housing in England.

The Regulator of Social Housing’s consumer standards apply from 1 April 2024, and its Code of Practice sets out what the Regulator looks for when it seeks evidence that a provider delivers their outcomes.

There are four: safety and quality; transparency, influence and accountability; neighbourhood and community; and tenancy.

None of them is a sustainability reporting standard, and none requires an ESG report.

They overlap with the SRS in subject matter — the quality and safety of homes, and damp and mould in particular — which is why SfH aligned those criteria in v2.1.

Treat the two as separate obligations with separate audiences: the Regulator’s standards are binding outcomes, and the SRS is a voluntary disclosure.

Regulator of Social Housing, Consumer standards Code of Practice.
Consumer standardApplies from
Safety and quality1 April 2024
Transparency, influence and accountability1 April 2024
Neighbourhood and community1 April 2024
Tenancy1 April 2024

Using both

Where the SRS data meets UK SRS, if a provider uses both

A provider that chooses to report against UK SRS S2 as well can reuse much of its SRS data.

This table is our reading of where the two meet; it is not a mapping published by either owner.

UK SRS S2 uses the four TCFD pillars; the SRS is organised by theme.
SRS criterionWhere it would sit under UK SRS S2What UK SRS adds
C5 — Scope 1, 2 and 3Metrics and targetsGross emissions measured to the GHG Protocol, with any net target beside them
C3 — net zero target and strategyMetrics and targets; strategyThe target’s basis, and progress against it
C3E — costed transition planStrategyHow the plan affects the business model and finances
C6–C8 — flood, water and overheating riskStrategy; risk managementThe financial effect on the entity, over stated time horizons
C4 — retrofit progressStrategy; metricsCapital allocated to the transition
Governance criteriaGovernanceBoard oversight of climate-related risks and opportunities specifically

The biggest difference is the question each asks.

UK SRS asks what could affect the entity’s cash flows, access to finance and cost of capital, in the four-pillar shape of the TCFD recommendations.

The SRS asks a wider set of ESG questions set for the sector, including how the provider’s homes affect the people who live in them.

SfH’s own expectation, in its September 2025 consultation response, was that housing associations are unlikely to face UK SRS requirements themselves, but will be asked for more ESG information by funders who do.

UK SRS stays voluntary for any provider whose shares are not listed in the five categories.

Dates

The dates that matter to a housing provider

The sector standard runs on its own cycle, with v2.1 reporting from October 2026.

The statutory dates come from the regimes a provider is actually in: ESOS for a large provider of any form, SECR for a large provider that is a company.

The FCA’s final rules apply from accounting periods beginning on or after 1 January 2027, and only to issuers in the five listing categories.

No requirement for unlisted bodies to use UK SRS has been proposed, and the modernising corporate reporting consultation, which closes on 30 November 2026, does not propose one.

The wider set of UK duties is set out on the sustainability reporting primer.

  1. 2020
    Sustainability Reporting Standard for Social Housing established
  2. 2023
    SRS v2.0 in use
  3. 1 Apr 2024
    RSH consumer standards apply
  4. 25 Feb 2026
    UK SRS S1 and S2 published

    Voluntary.

  5. 13 Apr 2026
    SRS v2.1 released
  6. 30 Sep 2026
    FCA final rules, PS26/19

    Bonds excluded.

  7. Oct 2026
    First reporting cycle on v2.1
  8. 30 Nov 2026
    Modernising corporate reporting consultation closes
  9. 31 Dec 2026
    ESOS Phase 4 qualification date
  10. 5 Dec 2027
    ESOS Phase 4 notification due

In practice

Running the SRS beside the statutory duties

One data set

Collect energy once

The kWh behind an ESOS assessment, the SECR figures and the SRS Scope 1 and 2 criteria are the same measurements.

Collect them once, for the whole boundary.

Boundaries

Say what is counted

The SRS counts homes the provider controls the energy standards of.

SECR counts energy the company is responsible for.

State each boundary where you report.

Modelled data

Label estimates

The v2.1 guidance accepts modelled EPC and energy data if disclosed as such.

A statutory report needs the same honesty about its methodology.

Assurance

Optional everywhere

No regime here requires assurance.

SfH reports that many housing associations seek it voluntarily for their sustainability data.

Talk it through

If you want to check where your organisation sits, a free 15-minute call can be booked on the booking page.

Frequently asked

Social housing ESG reporting: questions people ask

What is the Sustainability Reporting Standard for Social Housing?

It is a voluntary, sector-led ESG reporting standard for housing providers, owned by Sustainability for Housing, a not-for-profit company limited by guarantee.

The standard was established in 2020.

The current version, v2.1, was released on 13 April 2026 and is used from the October 2026 reporting cycle. It is free to download and report against.

Is the social housing SRS the same as UK SRS?

No. They share initials and nothing else.

UK SRS S1 and S2 are the UK Sustainability Reporting Standards published by the Department for Business and Trade on 25 February 2026.

The Sustainability Reporting Standard for Social Housing is a separate, voluntary sector standard with its own owner, criteria and reporting cycle.

Is ESG reporting mandatory for housing associations?

There is no ESG reporting duty for housing providers as such.

Which statutory regimes apply depends on legal form and size: a large company can be in SECR, any large undertaking — a registered society included — can be in ESOS, and a company with more than 500 employees in the s.414CA categories makes climate-related financial disclosures.

The sector standard and UK SRS are voluntary.

Do the FCA’s UK SRS rules apply to housing associations with listed bonds?

Not through the listing of bonds.

The FCA’s final rules (PS26/19) apply to listed companies in UKLR 6, 14, 15, 16 and 22, and exclude debt and debt-like securities in UKLR 17.

A housing provider whose only listed securities are bonds is not required by those rules to report against UK SRS.

What changed in SRS v2.1?

Sustainability for Housing cut the themes from 12 to 8, moved three governance criteria that rarely change into a new Adopter Profile, split multi-part criteria, added worked examples, aligned the damp and mould criteria with Awaab’s Law, added a tab mapping STAIR and ARC requirements, and added optional explanatory fields. v2.0 had been in use since 2023.

How many housing providers report against the SRS?

Sustainability for Housing’s 2026 Annual Review covers 104 Adopters managing over two million homes, based on the 2024/25 dataset.

In September 2025 SfH described the standard as having over 130 housing association adopters committed to reporting each year.

The two figures measure different things: the dataset and the commitments.

Does SECR apply to a housing association?

Only if it is a company or LLP. SECR sits in the Companies Act directors’ report, so a housing association that is a company and is over two of the three limbs — turnover more than £36 million, balance sheet more than £18 million, more than 250 employees — reports its energy and carbon there.

A registered society is not reached through that route.

What does the Regulator of Social Housing require on sustainability?

The Regulator’s consumer standards, in force from 1 April 2024, set outcomes on safety and quality; transparency, influence and accountability; neighbourhood and community; and tenancy.

They are not a sustainability reporting standard, and this page does not treat them as one.

Sources

Primary sources

Every figure, date and status on this page traces to the instrument’s owner.

Secondary commentary is never the source for a number.

Checked against 21 sources fromSustainability for HousingRegulator of Social Housinglegislation.gov.ukDepartment for Business and TradeFinancial Conduct AuthorityIFRS Foundation
  1. Sustainability for Housing
    Updating the Guidance on the SRS — Guidance for Version 2.1, Spring 2026 (PDF)

    v2.1 replaces v2.0; themes cut from 12 to 8; the criteria quoted on this page; the comply-or-explain approach.

  2. Sustainability for Housing
    Sustainability Reporting Standard updated to support evolving sector needs (13 April 2026)

    The v2.1 release and the October 2026 reporting cycle.

  3. Sustainability for Housing
    The Sustainability Reporting Standard for Social Housing — Annual Review 2026 (PDF)

    104 Adopters, over two million homes, the 2024/25 dataset.

  4. Sustainability for Housing
    SfH responses to the UK SRS and assurance-oversight consultations (18 September 2025)

    SfH’s own view of how UK SRS will reach housing providers through their funders.

  5. Sustainability for Housing
    The SRS — Adopter hub

    The standard’s home; the learning hub is for Adopters.

  6. Regulator of Social Housing
    Consumer standards Code of Practice

    Applies from 1 April 2024: safety and quality; transparency, influence and accountability; neighbourhood and community; tenancy.

  7. legislation.gov.uk
    Social Housing (Regulation) Act 2023 (c. 36)

    The Act that reformed consumer regulation of social housing in England.

  8. legislation.gov.uk
    Co-operative and Community Benefit Societies Act 2014, section 3

    A registered society is a body corporate.

  9. Department for Business and Trade
    UK Sustainability Reporting Standards — guidance

    UK SRS is available for voluntary use by any entity.

  10. Department for Business and Trade
    UK SRS S1 and UK SRS S2

    Published 25 February 2026.

  11. Financial Conduct Authority
    PS26/19 — Aligning listed issuers’ sustainability disclosures with international standards

    Comply or explain for UKLR 6, 14, 15, 16 and 22 from 2027.

  12. Financial Conduct Authority
    PS26/19 (PDF), ¶¶3.6–3.7

    Debt and debt-like securities (UKLR 17) are excluded.

  13. legislation.gov.uk
    SI 2008/410, Schedule 7, ¶¶20B and 20D

    The SECR exemption test and the 40,000 kWh de minimis.

  14. legislation.gov.uk
    ESOS Regulations 2014, Schedule 1

    The large-undertaking test.

  15. legislation.gov.uk
    ESOS Regulations 2014, regulation 16

    Public bodies are not relevant undertakings.

  16. legislation.gov.uk
    Companies Act 2006, section 414CA

    Who makes climate-related financial disclosures.

  17. legislation.gov.uk
    Companies Act 2006, section 474(1) — “traded company”

    Any transferable securities admitted to trading on a UK regulated market.

  18. IFRS Foundation
    IFRS Sustainability Disclosure Standards Navigator

    The ISSB standards UK SRS is built from.

  19. TCFD
    TCFD recommendations

    The four-pillar climate structure.

  20. GHG Protocol
    Corporate Accounting and Reporting Standard

    Scopes 1, 2 and 3, which the SRS asks for.

  21. Department for Business, Innovation, Science and Trade
    Modernising corporate reporting — consultation

    Open until 30 November 2026; proposes no UK SRS requirement for unlisted bodies.

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